20130110Comments.pdf

NEIL PRICE
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6864
FECE:
01.3JAN 10 PM 2:25
TiLITi CMMSStO
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
FIRST STEP INTERNET, LLC TO REGISTER ) CASE NO. FSI-T-12-01
AS A WHOLESALE TELECOMMUNICATIONS)
PROVIDER IN IDAHO.
) COMMENTS OF THE
) COMMISSION STAFF
)
COMES NOW the Staff of the Idaho Public Utilities Commission, by and through its
attorney of record, Neil Price, Deputy Attorney General, and in response to the Notice of
Application and Notice of Modified Procedure issued in Order No. 32699 on December 20, 2012,
in Case No. FSI-T-12-01, submits the following comments.
BACKGROUND
On October 12, 2012, First Step Internet, LLC ("FSI" or "Company") filed an
Application, pursuant to Commission Rule 114, IDAPA 31.01.01.114, as clarified in Procedural
Order No. 32277 in Case No. GNR-T- 11-01, for registration as a facilities-based provider of
wholesale local telecommunications services within the State of Idaho. Application at 1.
FSI has not yet initiated interconnection negotiations with any incumbent local exchange
carriers (ILECs). In the future, the Company intends to initiate negotiations with Frontier
Communications and potentially other ILECs. Id. at 2.
STAFF COMMENTS 1 JANUARY 10, 2013
STAFF ANALYSIS
FSI is an Idaho corporation and lists its principal place of business as Moscow, Idaho. Id.
at 1. FSI owns cable facilities that the Company will use to provide voice over Internet protocol
(VoIP) and Internet services.
FSI states that is has reviewed all of the Commission rules and agrees to comply with
rules applicable to competitive wholesale providers of local telecommunications services. The
Company has requested a waiver of rules not applicable to such service providers. Id. at 2.
FSI acknowledges that, if the Company obtains numbering resources in Idaho, it will be
subject to numbering conservation measures, including mandatory 1,000-block pooling, donation
back to the pool of unused or underutilized 1,000 number blocks, and submission of applicable
utilization/forecast reports at the one thousand block level for each rate center within its service
territory. Id. at 3.
STAFF RECOMMENDATION
Staff has reviewed the Application submitted by FSI for compliance with applicable legal
requirements to be registered as a wholesale provider of telecommunications services in Idaho
and believes the Company understands and agrees to comply with Commission Rules of
Procedure 114 and Commission Order No, 32277. Staff believes that FSI possesses the requisite
financial, managerial, and technical qualifications necessary to operate as a provider of
telecommunications services. Staff, therefore, recommends that the Commission approve FSI as
a registered wholesale communications provider subject to the following conditions:
1.The Company complies with number pooling and reporting requirements of the North
American Numbering Plan Administrator, as set forth in Commission Order No. 30425;
and,
2.FSI provides necessary reports and contributes as appropriate to the Idaho Universal
Service Fund (LJSF), Idaho Telecommunications Relay System (TRS), Idaho
Telecommunications Assistance Program (ITSAP), and complies with all future reporting
requirements deemed appropriate by the Commission for competitive telecommunications
providers.
STAFF COMMENTS 2 JANUARY 10, 2013
Respectfully submitted this day of January 2013.
eil Price
Deputy Attorney General
Technical Staff: Grace Seaman
i:umisc:comments/fsit12. I npgs comments
STAFF COMMENTS 3 JANUARY 10, 2013
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10TH DAY OF JANUARY 2013,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. FSI-T-12-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO
THE FOLLOWING:
SHARON THOMAS CONSULTANT
TECHNOLOGIES MGMNT INC
STE 300
2600 MAITLAND CTR PKWY
MAITLAND FL 32751
FIRST STEP INTERNET LLC
1420 S BLA1N ST
STE 10
MOSCOW ID 83843
SECRETARY/
CERTIFICATE OF SERVICE